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TCEQ Top 5 Pitfalls of NSR Permitting

Posted: November 14th, 2018

Authors: Rachel H. 

As the leaves begin to turn, and cooler weather rolls in, it’s clear that change is in the air.  This was not only true of the seasons but also the announcements at the 2018 Autumn Texas Commission on Environmental Quality (TCEQ) Conference held in Austin, Texas on October 9-10th.  The conference provided some quality reminders about the air permitting process that can benefit everyone – be sure to check out Thomas’ conference recap on New Source Review (NSR) permitting.

New Source Review (NSR) permitting can be tricky to understand, but even trickier to organize, especially the public notice (PN) portion.  The subject of the necessity of certain public notice aspects of the permitting process came up at the conference but were quickly dissolved since the notice is foundational to the process.  There may come a time when these rules change, but for now we should all hold on to our relationships with the local newspaper and sign makers. Outside of public notice, there are many other parts to the NSR permitting process.  The TCEQ dove into the process in general and highlighted the top 5 problems that come across TCEQ’s desks.  Below is a compiled list of these top 5 pitfalls and some tips on how to avoid them.

Incomplete application

We all get caught up in a new task and lose track of work, but this pitfall is more concerned with submitted applications that are missing key information such as plot plans, Table 1-A emission point summary, and even certain formatting requirements.  There are lots of little parts to the application, so the best option is to read through the PI-1 and PI-1R instructions before, during, and after preparing an application.  Also starting early and staying organized head off a ton of problems.

Emissions calculations

Permit reviewers receive these calculations and must recreate them for verification.  TCEQ must be provided with detailed instructions and information on all the sources used to complete the emissions calculations.   Providing accurate, detailed information will make their lives easier and the review process more efficient.  Small reminders: use scientific notation (no zeros!) and be ready to submit your spreadsheets electronically if asked.

Public notice errors

There are many steps to this portion (as we already alluded to), but every detail is in the notice letter received from the TCEQ. Read it carefully!  Always check the school districts for a bilingual program before beginning the process, and when calling around to public sign makers and posting locations, remember that this process isn’t new.  Usually someone working at these locations has been through it before, so keep asking around until you find the experienced ones.  Lastly, pay close attention to the timelines. The deadlines come up quickly and need to be addressed early.

Unfamiliarity with permitting

TCEQ’s suggestion for this one was a bit brutal.  Essentially, you can get familiar, or consider hiring someone who is qualified and experienced… like ALL4.  Whether you are entirely unfamiliar, or a seasoned professional who just doesn’t have time, we are here to help.

Response times

The final pitfall is one that catches us in every aspect of life: deadlines.  Our tip to you is to stay organized.  Put the deadlines on your calendar, in a spreadsheet, or anywhere you will frequently check on them. It’s simple to say, but the execution is rarely as smooth.

The last bit of advice is that the TCEQ is always available for phone calls.  Every speaker at the event offered their desk phone number and to respond to any questions or concerns with their topic. Don’t be afraid to pick up the phone and give them a call.  And if this is all too much…. give your friends at ALL4 a call because air quality compliance is clearly our business.  Please contact me at (281) 937-7553, extension 304 or rhenn@all4inc.com of you have any questions.


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